County staff outlines CDBG/HOME technical requests to Congress, discusses TBRA tweaks and implementation challenges

Rebecca Royce and program staff briefed the Urban County Policy Board on recent program updates and described a staff letter responding to a congressional request for information on CDBG and HOME programs.

Royce told the board that Chairman Mike Flood and Ranking Member Emanuel Cleaver had requested information from entitlement jurisdictions; staff prepared recommendations to increase the CDBG public-service cap, expand allowable HOME/TBRA uses (including deposit limits), and provide implementation relief on Build America Buy America (BABA) requirements and environmental-review thresholds for small neighborhood infrastructure projects. Royce said the county’s letter seeks changes to allow more flexible case-management reimbursements under CDBG/HOME-funded tenant-based rental assistance (TBRA) programs, to ease the administrative burden that currently delays reimbursement until HOME dollars are expended, and to raise allowable deposit amounts beyond the current HOME cap (currently limited to two times one month’s rent for some HOME-funded deposit assistance).

Royce said the county is asking HUD and Congress to reconsider the application of BABA requirements to small projects because current guidance and reporting has proven complex for some local governments and can slow or increase the cost of affordable housing and neighborhood improvement projects. She also asked for a narrower environmental-review requirement for small infrastructure and neighborhood-improvement projects, noting that adding stormwater, sidewalks, or similar work can elevate projects from a Categorical Exclusion to an Environmental Assessment and trigger additional climate/energy analysis, which staff said can be disproportionate for smaller projects.

Board members discussed TBRA operations. Rebecca and Michael Torres explained that Clark County's TBRA rapid-rehousing programs use coordinated entry and typically require at least annual income recertification (many providers recertify every three months); a household with income above HUD thresholds must be exited. Torres and Royce said most households served under TBRA are at or below 30% of area median income in practice, and staff asked for flexibility in HOME/TBRA rules to better support wraparound services, reimburse providers for pre-housing costs and allow higher deposit payments when necessary.

Royce said the county’s draft letter will be submitted to members of Congress and that national associations—NACo and the National Community Development Association—are preparing responses as well. She offered to share the county’s letter with cities and the board encouraged staff to circulate the text to local jurisdictions and nonprofit partners.